Moldovan businesses are asking for a six-year delay in the introduction of a global minimum tax after the country's accession to the EU
Moldova's largest business associations have appealed to the government and parliament, asking the European Commission to grant the country a six-year transition period to implement the global minimum tax rules (Pillar II), as stipulated by EU Directive 2022/2523. This position is set out in a document prepared jointly by AmCham Moldova, EBA Moldova, FIA Moldova, and ATIC. The letter emphasizes that the signatories support the harmonization of tax legislation with EU standards, but believes that the immediate application of Pillar II rules would create an excessive administrative burden with minimal tax impact. The document notes that the country is simultaneously implementing a large-scale tax reform, continues to suffer the consequences of the war in Ukraine, and needs to strengthen its administrative capacity to implement such complex mechanisms. Business representatives point out that Article 50 of the EU Directive allows small countries with a limited number of large international groups to defer the application of key rules, the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR). Estonia, Latvia, Lithuania, Malta, and Slovakia have already taken advantage of this opportunity. Business associations estimate that Moldova is in a comparable situation: the country lacks ultimate parent entities (UPEs) subject to the Directive, and the number of local subsidiaries of large international groups is estimated at approximately 50 companies. Particular attention is being paid to the Moldova IT Park. Businesses warn that premature application of the new rules could jeopardize the special tax regime guaranteed for park residents until 2035, reduce the investment attractiveness of the IT sector, and negatively impact investor confidence in state guarantees. Furthermore, uncertainty remains regarding how the current flat tax in the IT Park should be taken into account when calculating the effective tax rate under the GloBE rules. The appeal also emphasizes that the implementation of Pillar II will require the creation of a new IT infrastructure, the modernization of tax administration systems, specialist training, the organization of international data exchange, and the adaptation of corporate reporting. For a limited number of potentially affected companies, according to businesses, such costs will be disproportionate to the expected budget revenues. Therefore, the business community proposes that Moldova's official position in negotiations with the European Commission include a transition period similar to the mechanism under Article 50 of the EU Directive, deferring the application of the IIR and UTPR rules for six years after EU accession. The country also maintains its commitment to transposing the directive into national legislation, developing its administrative infrastructure, and fully implementing the global minimum tax mechanism after the end of the transition period. // 03.07.2026 – InfoMarket.
